A nanocrystal non-volatile memory (NVM) has a dielectric between the control gate and the nanocrystals that has a nitrogen content sufficient to reduce the locations in the dielectric where electrons can be trapped. This is achieved by grading the nitrogen concentration. The concentration of nitrogen is highest near the nanocrystals where the concentration of electron/hole traps tend to be the highest and is reduced toward the control gate where the concentration of electron/hole traps is lower. This has been found to have the beneficial effect of reducing the number of locations where charge can be trapped.